The state Independent System Operator is sounding new alarms over the state’s electric grid – and is again facing pushback from an environmental group that disagrees with its analysis.

The state ISO recently released its 2025-2034 Comprehensive Reliability Plan. The report finds that the electric grid faces growing risks of uncertainty because of the rapid growth of large loads from things like microchip manufacturing and AI-related data centers; the aging generation fleet; and a lack of new dispatchable generation resources being added to the system. The Comprehensive Reliability Plan is issued every two years to identify and address potential risks to reliability on the electric system.

The Comprehensive Reliability Plan released in November states that, in the opinion of the ISO, the future reliability of the grid depends on the development of flexible generation capable of performing during extended periods of high consumer demand and extreme weather.

The report examines lessons-learned from the June 2025 heatwave and the need for a planning framework that better reflects present challenges of operating the grid while anticipating plausible future risks.

“The system requires additional dispatchable generation to serve forecasted increases in consumer demand,” said Zach Smith, ISO senior vice president, system and resource planning. “We also need to refine and evolve our planning processes to better reflect this period of great change on the grid and a broader range of plausible future outcomes.”

The CRP demonstrates that due to emerging reliability challenges, traditional planning methods built around a single forecast are no longer sufficient. To maintain system reliability and protect public safety, the economy and quality of life, the CRP recommends actions that will strengthen planning processes across a broad spectrum of system conditions and advance needed investment before reliability margins disappear.

While this 2025-2034 Comprehensive Reliability Plan (CRP), under current applicable reliability criteria and procedures, identifies no actionable Reliability Needs, ISO officials said finding no reliability needs that need action to be taken shouldn’t be mistaken for long-term system adequacy. The margin for error is narrow, ISO officials wrote in the executive summary of the newest reliability plan, and ISO forecasts point to significant reliability shortfalls within the next 10 years, the summary states. Depending on demand growth and retirement patterns, the system may need several thousand megawatts of new dispatchable generation over the next 10 years.

At the same time, Earthjustice officials say the Comprehensive Reliability Plan (CRP) could lead to higher energy bills and further spending on natural gas and nuclear power. Chief among Earthjustice’s complaints are the lack of ISO support for claims about projected energy shortfalls. Much of the content in its executive summary is not backed up by the ISO’s analysis, the advocacy organization states, like the claims about the need for dispatchable resources

“NYISO’s Comprehensive Reliability Plan does not back up its rhetoric. New Yorkers do not want their electricity bills driven ever higher by unneeded payments to dirty energy generators. Instead of doubling down on yesterday’s expensive technologies-like burning fracked gas, which NYISO leaders themselves warn presents the greatest risk to winter reliability-policymakers and stakeholders should follow the facts, which point to the many benefits of investments in transmission and modern technologies like solar, wind, and batteries. Just look at this past summer, when renewables overperformed expectations during the heatwave, reducing peak demand and pulling down prices. At the same time, the dirty generators underperformed yet again,” said Michael Lenoff, Senior Attorney at Earthjustice.

The public fight over the ISO’s reliability concerns come amid a larger fight at the state level over the future of the Climate Leadership and Community Protection Act. A state Supreme Court justice in Ulster County ruled on behalf of environmental groups who sued the state for not issuing regulations that would “ensure” New York meet aggressive emissions targets that are part of the Climate Leadership and Community Protection Act signed into law in 2019. The targets require the state to cut emissions by 40% from 1990 levels by 2030 and 85% from 1990 levels by 2050. The case was brought in March after Gov. Kathy Hochul didn’t implement cap-and-invest emissions pricing program over concerns about costs on state ratepayers. Hochul has said the CLCPA could be modified before the judge’s February 6 deadline for the state to take action.